WQCS00047_NOV-2024-DV-0084 Response to Notice_20240311

Public Works Department
CITY OF SANFORD
P. O. BOX 3729 TELEPHONE [phone]
FAX [phone] North Carolina 27331-3729 or 919-777-1122
Victor I. Czar P.E.
Assistant City Manager

March 11, 2024

Michael Hall, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
3800 Barrett Drive
Raleigh, NC 27609

RE: Notice of Violation
NOV-2024-DV-0084
Permit No. WQCS00047
City of Sanford Collection System
Lee County

Dear Mr. Hall:

We are in receipt of the above referenced Notice of Violation, received February 26,
2024, which involved overflows occurring January 9-16, 2024. These took place in three
separate areas of the City’s system.

Of the Incidents recorded, all but one were the result of a severe natural occurrence.

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Little Buffalo Basin

Incident Number Location Date of Incident
202400119 305 East Rose St 1/9/2024
202400117 223 Maple Avenue 1/9/2024
202400118 200 Hickory Avenue 1/9/2024
202400287 223 Maple Avenue 1/12/2024
202400288 200 Hickory Avenue 1/12/2024
202400289 305 East Rose St. 1/12/2024

The overflows were the result of a severe natural occurrence. On 1/6, approximately 0.8
inches of rainfall was recorded with no incidents taking place. However, on 1/9 four
events took place (listed below) and the rain gauges recorded 0.7 to 2.2 inches of rainfall
during that time. On 1/12 three more incidents occurred with another rain event where the
rain gauges registered values ranging from 0.7 to 1.4 inches.

Overflows have occurred in the past at these locations. To address them, two projects
are underway:

1. East Sanford CDBG
The City received a $2 million CDBG-I grant to rehabilitate sections of sewer line
downstream of this location. The bulk of this project involves cured-in-place
lining which will minimize infiltration in the older sewer lines, resulting the
recovery of capacity.

This project has been in design for quite some time. We went through a number
of attempts to bid the project and get contractors interested in the project. In
January of 2024 we were finally able to award this project to a contractor. He is
expected to start work in June of this year with projected completion being June
2025.

2. Little Buffalo Rehabilitation – Upper Reach
The City was awarded a $3.8 million Clean Water State Revolving Fund loan to
upsize a section of Little Buffalo outfall which would help resolve the overflow
events by increasing capacity. We are increasing the pipe size from 12 inch to 18
inch. An alternate alignment of the outfall resulted in an extension of the design
time.

Construction is expected to start in November of 2025 with project completion in
June of 2026.

The City expects both of these projects to have a significant impact on the overflows we
have been seeing in this basin.
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Dry Creek Basin

The overflows were the result of a severe natural condition. They occurred during the
same time frames as the incidents in Little Buffalo basin.

This area has seen repetitive overflows in the past. Modeling and flow monitoring have
been performed in this area. CCTV and smoke testing is underway this year. We
anticipate repairs will be made this year and next. In addition, we expect additional
CCTV and smoke testing to take place next year due to the size of the basin.

Big Buffalo Basin

This incident was a pipe failure which was caused by a large tree falling across the pipe.
The City inspects is rights of way at least twice a year with an eye on managing any
growth that may have the potential of damaging our infrastructure. Unfortunately, the
tree in question was outside of the City’s right of way.

Incident Number Location Date of Incident
202400122 2002 Shoreline Drive 1/9/2024

This incident was the result of a severe natural condition. This occurred over the same
time as the other incidents discussed above. The City experienced a 0.86 inch rain event
on 1/6 followed by a 2.1 inch on 1/9, the date of the incident.

The City has performed flow monitoring in this area and have identified some parts of the
system for further investigation. CCTV and smoke testing work will be scheduled next
fiscal year to look for I/I routes.

Incident Number Location Date of Incident
202400116 522 Sunset Drive 1/9/2024
202400286 522 Sunset Drive 1/12/2024
Incident Number Location Date of Incident
202400292 Manhole 4146-4145 (near
Forestwood Park Drive)
1/16/2024
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Should you have any questions, please feel free to contact me at any time.

Sincerely,

Paul M. Weeks Jr., P.E.
Executive Director of Utilities

cc: Gerald Cox, Director of Distribution and Collection Systems
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